UK reviews corporate-tax financing, investment reliefs and reporting

Financing and anti-avoidance

Options include simpler interest treaty-relief procedures, potentially limited self-assessment. CFC rules would remain, with possible Pillar Two alignment; anti-hybrid counteractions for Pillar Two groups will also be reviewed. Neither regime is presently disapplied. Unallowable-purpose work explores clearer guidance and fiscally neutral changes. Major corporate-interest-restriction simplification remains constrained by revenue and policy risks.^[2]

Investment reliefs

The programme covers R&D eligibility and claims administration, Patent Box calculation steps and income streaming, capital-allowance predevelopment costs and capital-intensive projects. It also considers relevant-asset restrictions, partnerships and IP licences under Part 8 of the Corporation Tax Act 2009. These are reform areas, not new deductions or eligibility entitlements.^[2]

Reporting and next steps

The government intends to remove separate six-month international-movements-of-capital reporting and consider alternative information channels. No repeal commencement date is supplied. R&D form integration and wider large-business reporting reviews are also contemplated. Expressions of interest are requested by 21 November 2026, not a tax-filing deadline. Groups should document duplication and uncertainty while retaining current obligations; this paper does not establish a present filing relaxation.^[2]